Comment on FR Doc # 2026-11765
LRAE ENTERPRISE INCSupportBusiness
Summary: Anthony White, owner of LRAE ENTERPRISE INC, supports the proposed reforms but requests that the SBA provide clearer guidance on evidence sufficiency, specific examples of "material harm," a firm date to resume processing applications, and a transition period for current applicants. He emphasizes the need for a transparent and functioning path to federal contracting for small businesses in underserved communities.
See attached file(s)Comment of LRAE ENTERPRISE INC — Anthony White, President and Director. I am the sole owner of a South Los Angeles small business providing transitional and reentry housing, and a prospective individually owned 8(a) applicant currently assembling an application under the standard this rulemaking would revise. I submit this comment as a directly regulated and affected party, timely before the July 13, 2026 close, and request that it be entered into the docket. My full comment is attached.
POSITION: I do not oppose the reform. I ask only that whatever standard SBA adopts be published clearly, applied consistently, and actually administered. The value of the 8(a) program to a firm like mine lies not in any presumption, but in a fair, functioning, and transparent path to federal contracting.
SUMMARY OF RECOMMENDATIONS:
1. Sufficiency guidance (proposed 13 CFR 124.103(b)). The two-part evidence test is workable, but the rule does not state how much evidence suffices or which sources SBA treats as authoritative. SBA should publish, concurrent with the final rule, a plain-language guide with worked examples of a complete, approvable submission. The prior "Guide for Demonstrating Social Disadvantage" was removed; small firms without counsel are disproportionately harmed by the resulting ambiguity.
2. Define "material harm" with certifiable specificity. Applicants self-certify under penalty of perjury and potential False Claims Act exposure. A standard that is broad on its face but undefined in application is untenable. SBA should provide illustrative examples of qualifying harm — e.g., denial of credit, denial of contracting opportunity, or diminished access to capital — so applicants can certify accurately and in good faith.
3. Address the processing freeze. SBA has not approved a new individually owned 8(a) application since approximately August 2025 and admitted only about 65 firms in all of FY2025. A certification program that certifies no one is not race-neutral; it is closed, and firms in underserved communities — those least able to absorb a year of limbo — bear that closure most heavily. SBA should announce a firm date to resume processing individually owned applications and publish a service-level target for adjudication.
4. Provide transition and a clear effective date. Applicants who began assembling materials under the prior standard have invested substantial time and expense. SBA should specify a clear effective date and a reasonable transition window allowing applicants to supplement rather than restart submissions.
I respectfully request that SBA address these four recommendations in its response to comments in the final rule. As a directly affected small business owner, I am available to serve as a resource to the Agency on the real-world administrability of the proposed standard.
Small businesses in communities like South Los Angeles do not need advantages. We need a door that opens. Please see the attached document for my full comment.